PREFACE This document is a protocol template for clinical studies that pose greater than minimal risk to study subjects and will require review by the full IRB. Minimal risk is defined by 45 U.S. Code of Federal Regulations (CFR) 46.102 (i) as follows: “Minimal risk means that the probability and magnitude of harm or discomfort anticipated in the research are not greater in and of themselves than those ordinarily encountered in daily life or during the performance of routine physical or psychological examinations or tests.” Refer to: http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.htm#46.102 Note that instructions and explanatory text are indicated by italics and should be replaced in your protocol document with appropriate protocol-specific text. Section headings and template text formatted in regular type should be included in your protocol document as provided in the template. Throughout this protocol template, there may be subject headings that do not apply to your particular study. In such instances, please write “not applicable.” In places where the information is duplicative, it is acceptable to reference another section rather that repeating the information. After the sections in this template has been answered, you will need to update the Table of Contents for this document. Consult with computer support within your department for assistance. ____________________________________________________________________________________________ TITLE Protocol Number: Protocol number required. Sponsored by: Principal Investigator: Medical Monitor: If applicable Draft or Version Number: Month, Day, Year This template is adapted from the ICH guidance document E6 (Good Clinical Practices), Section 6. ____________________________________________________________________________________________ Statement of Compliance Provide a statement that the trial will be conducted in compliance with the protocol, International Conference on Harmonization Good Clinical Practice (ICH GCP) and the applicable regulatory requirements. An example is provided below: The study will be carried out in accordance with Good Clinical Practice (GCP) as required by the following [use applicable regulations depending on study location and sponsor requirements; samples follow]: U.S. Code of Federal Regulations applicable to clinical studies (45 CFR 46) ICH GCP E6 Completion of Human Subjects Protection Training Refer to: http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.htm#46. http://www.fda.gov/cder/guidance/959fnl.pdf http://grants.nih.gov/grants/guide/notice-files/NOT-OD-01-061.html http://cme.cancer.gov/c01/ ____________________________________________________________________________________________ i SIGNATURE PAGE The signature below constitutes the approval of this protocol and the attachments, and provides the necessary assurances that this trial will be conducted according to all stipulations of the protocol, including all statements regarding confidentiality, and according to local legal and regulatory requirements and applicable US federal regulations and ICH guidelines. Principal Investigator Signed: Name Title Date: ____________________________________________________________________________________________ ii Table of Contents page Statement of Compliance ................................................................................................................. i Signature Page ................................................................................................................................ ii List of Abbreviations ........................................................................................................................ v Protocol Summary .......................................................................................................................... vi 1 2 3 4 5 6 7 8 Key Roles ............................................................................................................................... 1 Background Information and Scientific Rationale ................................................................. 2 2.1 Background Information ............................................................................................. 2 2.2 Rationale .................................................................................................................... 2 2.3 Potential Risks and Benefits ...................................................................................... 2 2.3.1 Potential Risks ............................................................................................... 2 2.3.2 Known Potential Benefits ............................................................................... 3 Objectives .............................................................................................................................. 4 Study Design .......................................................................................................................... 5 4.1 Selection of the Study Population.............................................................................. 5 4.2 Inclusion/Exclusion Criteria ....................................................................................... 6 Study Procedures/Evaluations .............................................................................................. 7 5.1 Study Procedures ...................................................................................................... 7 5.2 Laboratory Evaluations .............................................................................................. 7 5.2.1 Laboratory Evaluations/Assays ..................................................................... 7 5.2.2 Special Assays or Procedures ....................................................................... 7 5.2.3 Specimen Collection, Preparation, Handling and Shipping .......................... 8 5.3 Subject Compensation ............................................................................................... 8 Study Schedule ...................................................................................................................... 9 6.1 Screening ................................................................................................................... 9 6.2 Enrollment/Baseline, if applicable ............................................................................. 9 6.3 Follow-up and Final Visits, if applicable .................................................................... 9 6.4 Early Termination Visit, if applicable ......................................................................... 9 6.5 Criteria for Discontinuation or Withdrawal of a Subject (or a Cohort), if applicable 10 Assessment of Outcome Measures .................................................................................... 11 7.1 Specification of the Appropriate Outcome Measures.............................................. 11 7.1.1 Primary Outcome Measures ........................................................................ 11 7.1.2 Secondary Outcome Measures ................................................................... 11 Safety assessment and reporting ........................................................................................ 12 8.1 Definition of Adverse Event (AE) ............................................................................. 12 8.2 Definition of Serious Adverse Event (SAE) ............................................................. 12 8.3 Reporting Procedures .............................................................................................. 13 8.3.1 Serious Adverse Event Detection and Reporting ........................................ 13 8.3.2 Reporting of Pregnancy ............................................................................... 14 8.3.3 Procedures to be Followed in the Event of Abnormal Laboratory Test Values or Abnormal Clinical Findings .......................................................... 14 ____________________________________________________________________________________________ iii Table of Contents - continued page 8.3.4 Type and Duration of the Follow-up of Subjects After Adverse Events ...... 14 8.4 Halting Rules ............................................................................................................ 14 9 Clinical Monitoring Structure ................................................................................................ 16 9.1 Site Monitoring Plan ................................................................................................. 16 10 Statistical Considerations .................................................................................................... 17 10.1 Study Outcome Measures ....................................................................................... 17 10.2 Sample Size Considerations ................................................................................... 17 10.3 Participant Enrollment and Follow-Up ..................................................................... 17 10.4 Analysis Plan............................................................................................................ 17 11 Access to Source Data/Documents ..................................................................................... 19 12 Quality Control and Quality Assurance ............................................................................... 20 13 Ethics/Protection of Human Subjects .................................................................................. 21 13.1 Declaration of Helsinki ............................................................................................. 21 13.2 Institutional Review Board ....................................................................................... 21 13.3 Informed Consent Process ...................................................................................... 21 13.3.1 Informed Consent/Assent Process (in Case of a Minor or others unable to consent for themselves) ............................................................................... 23 13.4 Exclusion of Women, Minorities, and Children (Special Populations) .................... 23 13.5 Subject Confidentiality ............................................................................................. 23 13.6 Future Use of Stored Specimens ............................................................................ 24 14 Data Handling and Record Keeping .................................................................................... 25 14.1 Data Management Responsibilities ......................................................................... 25 14.2 Data Capture Methods ............................................................................................. 26 14.3 Types of Data ........................................................................................................... 26 14.4 Timing/Reports ......................................................................................................... 26 14.5 Study Records Retention ......................................................................................... 26 14.6 Protocol Deviations .................................................................................................. 26 15 Publication Policy ................................................................................................................. 27 16 Literature References .......................................................................................................... 28 EXAMPLE: Data and Safety Monitoring Plan ................................................................................ 32 SUPPLEMENTS/APPENDICES A: Study Schedule ____________________________________________________________________________________________ iv ____________________________________________________________________________________________ List of Abbreviations AE CFR CRF DSMB FDA FWA GCP ICF ICH IRB JAMA MOP N NEJM NIH OHRP PI SAE Adverse Event Code of Federal Regulations Case Report Form Data and Safety Monitoring Board Food and Drug Administration Federal-Wide Assurance Good Clinical Practice Informed Consent Form International Conference on Harmonisation Institutional Review Board Journal of the American Medical Association Manual of Procedures Number (typically refers to subjects) New England Journal of Medicine National Institutes of Health Office for Human Research Protections Principal Investigator Serious Adverse Event This list should be expanded to include protocol-specific terms. ____________________________________________________________________________________________ v Protocol Summary Limit to 1-2 pages Title: Population: Include sample size, gender, age, general health status, geographic location Number of Sites: 3 or fewer, list here; otherwise, list only in an Appendix and in Section 1 Study Duration: State duration of study Subject Duration: State duration per subject Objectives: Include primary/secondary outcome measures and method by which outcome will be determined; copy objectives and clinical/laboratory outcome measures from the appropriate sections of the protocol. Include a sentence or two about efficacy and safety assessments. Primary: Secondary: Schematic of Study Design: Optional ____________________________________________________________________________________________ vi Example: Flow diagram Prior to Enrollment Total N: Obtain informed consent. Screen subjects by criteria; obtain history document. Study Procedure, Intervention, or Specimen Collection Study Visit 1 Study Visit 2 Assessment Etc. Assessment of Final Study Outcome Measures ____________________________________________________________________________________________ vii 1 KEY ROLES See ICH E6 GCP, Section 6.1 (http://www.fda.gov/cder/guidance/959fnl.pdf). Individuals: Principal Investigator: Medical Monitor: (if applicable) Provide the following information: Name, degree, title Institution Address Phone Number Fax Number E-mail Institutions: Study sites, Clinical laboratory (ies) and other medical or technical departments and/or institutions, as applicable. Provide the following information for each organization or institution: Institution Address Contact Person Phone Number Fax Number E-mail Optional: Consider listing, for example Major International Collaborators, if not included as site investigators Protocol Data Manager, Epidemiologist, Statistician Industry Representative(s) Other individuals should be listed in a separate document (e.g., the Manual of Procedures) as appropriate ____________________________________________________________________________________________ 1 2 BACKGROUND INFORMATION AND SCIENTIFIC RATIONALE 2.1 Background Information See ICH E6 GCP, Section 6.2 (http://www.fda.gov/cder/guidance/959fnl.pdf). Include: Hypothesis of study A summary of findings from studies that have potential significance to proposed study Discussion of important literature and data that are relevant to the study and that provide background for the study (reference citations in Reference section) Applicable clinical, epidemiological or public health background or context of the study 2.2 Rationale Include a description of and justification for selection of study population. 2.3 Potential Risks and Benefits Include a discussion of known risks and benefits, if any, to human subjects. Refer to 45 CFR Part 46.116 (a) (2) and (3). http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.htm#46.116 2.3.1 Potential Risks Describe in detail any physical, psychological, social, legal, economic or any other risks to subjects that the PI foresees, as to each of the following: Immediate risks Long range risks Rationale for the necessity of such risks ____________________________________________________________________________________________ 2 Alternative data gathering procedures that have been considered or will be considered Why alternative procedures may not be feasible Why the value of the information to be gained outweighs the risks involved. 2.3.2 Known Potential Benefits If the research is beneficial (i.e., the subject derives a direct benefit of either money or treatment from participating in the study), describe in detail any physical, psychological, social, legal, economic or any other benefits to subjects that the PI foresees, as to each of the following: ____________________________________________________________________________________________ 3 3 OBJECTIVES A detailed description of the objectives of the study is included in this section. These typically include: Statement of purpose e.g., to assess, to determine, to compare, to evaluate Method of assessing how the objective is met, i.e., the study outcome measures ____________________________________________________________________________________________ 4 STUDY DESIGN 4 See ICH E6 GCP, Section 6.4 (http://www.fda.gov/cder/guidance/959fnl.pdf). The scientific integrity of the study and the credibility of the data from the study depend substantially on the study design. A description of the study design should include: A description of the design of the study to be conducted, including controls Approximate time to obtain specimens Expected duration of subject participation Description of subject participation (e.g., number of times and the frequency at which a subject will provide specimens) Methods for collecting specimens and data. A specific statement of the primary and secondary outcomes to be measured during the study (must be consistent with Study Objectives, as stated in Section 3) Identify structure for safety oversight (e.g., DSMB, Study Population) 4.1 Selection of the Study Population If the study intends to enroll children, pregnant women, prisoners, or other vulnerable populations, see applicable section of 45 CFR 46 Subpart B – Additional DHHS Protections Pertaining to Research, Development and Related Activities Involving Fetuses, Pregnant Women, and Human In Vitro Fertilization (45 CFR 46.201-46.211); Subpart C – Additional DHHS Protections Pertaining to Biomedical and Behavioral Research Involving Prisoners as Subjects (45 CFR 46.301-46.306); Subpart D – Additional DHHS Protections in Children Involved as Subjects in Research (45 CFR 46.401-409). Please refer to these guidelines when choosing the study population. Refer to: http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.htm#46. Provide the target sample size, including actual numbers to be enrolled. Include numbers of women, minorities and children expected to be recruited. If women, minorities and children will not be recruited, explain why not. Provide justification for Exclusion in Ethics/Protection of Human Subjects, Section 14.4. Refer to: http://grants2.nih.gov/grants/funding/women_min/women_min.htm Indicate from where the study population will be drawn (e.g., inpatient hospital setting, outpatient clinics, student health service). Where appropriate (single center studies), include names of hospitals, clinics, etc. ____________________________________________________________________________________________ 5 Identify strategies for subject recruitment and retention. If subjects require screening: distinguish between screening subjects (e.g., discussing the study with them) vs. enrolling subjects (e.g., obtaining informed consent and obtaining samples). Note: if screening procedures are required for eligibility (e.g., laboratory tests), there must be a separate screening consent form in addition to the informed consent form for study participation. Eligibility Criteria The eligibility criteria should provide a definition of subject characteristics required for study entry. The same criterion should not be listed as both an inclusion and exclusion criterion (e.g., do not state age >32 years old as an inclusion criterion and also age ≤32 years old as an exclusion criterion). Select screening laboratory tests carefully, if they will be used. 4.2 Inclusion/Exclusion Criteria Provide a statement that subject must meet all of the inclusion criteria to participate in this study and then list each criterion. Examples include the following: informed consent obtained and signed, age, presence or absence of a medical condition/disease, required laboratory result, understanding of study procedures, ability to comply with study procedures for the entire length of the study. Provide a statement that all subjects meeting any of the exclusion criteria at baseline will be excluded from study participation and then list each criterion. Examples include the following: medical condition or laboratory finding that precludes participation, recent (with time frame) febrile illness that precludes participation, pregnancy or breast feeding. ____________________________________________________________________________________________ 6 STUDY PROCEDURES/EVALUATIONS 5 Information outlined in the Procedures/Evaluations section should refer to and be consistent with the information in the Schedule of Procedures/Evaluations in Appendix A. 5.1 Study Procedures Specify the type of information that will be gathered, along with the means for collecting and recording data. List all relevant clinical evaluations to be done during the protocol, if any, and provide details of what are included and special instructions. Examples: Specimen collection Medical history Concomitant medications Physical exam Counseling procedures. 5.2 Laboratory Evaluations 5.2.1 Laboratory Evaluations/Assays List all laboratory evaluations, if applicable. Include specific test components and estimated volume and type of specimens needed for each test. Specify laboratory methods (e.g., use consistent laboratory method throughout study). Provide descriptions of assays to be performed. 5.2.2 Special Assays or Procedures List special assays or procedures required to assess the study product (e.g., immunology assays, PK studies, photographs). For laboratory assays, include specific assays, estimated volume and type of specimen needed for each test. For procedures, provide special instructions or precautions. If more than one laboratory will be used, specify which assays or evaluations will be done by each laboratory. ____________________________________________________________________________________________ 7 5.2.3 Specimen Collection, Preparation, Handling and Shipping 5.2.3.1 Instructions for Specimen Preparation, Handling, and Storage Special instructions for the collection, labeling, preparation, handling, and storage of specimens should be summarized in this section and clearly detailed in a Manual of Procedures. These instructions include required temperatures, aliquots of specimens, whether samples will be frozen, where they will be stored, how they will be labeled, etc. Include a discussion of long-term access and consent for future use. There may need to be additional considerations for biological specimens, especially biohazardous specimens that require special containment. 5.2.3.2 Specimen Shipment State the frequency with which specimens are to be shipped and to what address. Include contact information for laboratory personnel. Include days and times shipments are allowed and any labeling requirements for specimen shipping. Also, any special instructions such as dry ice or wet ice or the completion of a specimen-tracking log are included. Place specific details in a Manual of Procedures and reference within the protocol. 5.3 Subject Compensation Provide information regarding any compensation and/or reimbursement which will be provided. What is the difference between compensation and reimbursement? A reimbursement is used when the subject is paid back for travel expenses such as mileage, lodging, food while traveling. Receipts or mileage must be submitted for a reimbursement. Compensation is "payment" for things such as time, discomfort, inconvenience. Total possible compensation should reflect the true value of the total possible dollar amount per participant for one year involvement in the study whether it be cash, check, gift card, goods, etc. or a combination of these items. ____________________________________________________________________________________________ 8 6 STUDY SCHEDULE Information outlined in the Study Schedule section should refer to and be consistent with the information in the Schedule of Procedures/Evaluations in Appendix A and in Section 6. The evaluations to be done must be listed individually in this section or alternatively, refer to the Schedule of Procedures/Evaluations (Appendix A). Allowable windows should be stated for all visits. 6.1 Screening This section must include instructions for obtaining signed informed consent. Following consent, include only those evaluations necessary to assess whether a subject meets enrollment criteria. Discuss the sequence of events that should occur during screening and decision points regarding eligibility. List the timeframe prior to enrollment within which screening tests and evaluations must be done (e.g., within 28 days prior to enrollment). 6.2 Enrollment/Baseline, if applicable If applicable, include discussion of evaluations/procedures necessary to assess or confirm whether a subject still meets the eligibility criteria and may be enrolled. 6.3 Follow-up and Final Visits, if applicable Include discussion of evaluations/procedures. Discuss the sequence of events that should occur during the visit, if applicable. Include, as applicable, counseling, medications, adverse events, etc. Define when the final study visit should occur and any special evaluations or instructions to the subject. 6.4 Early Termination Visit, if applicable Specify which of the evaluations required for the final study visit should be done at a termination visit if early termination occurs and if the participant is willing. Subjects may withdraw voluntarily from participation in the study at any time. ____________________________________________________________________________________________ 9 6.5 Criteria for Discontinuation or Withdrawal of a Subject (or a Cohort), if applicable List possible reasons for discontinuation of a subject in this section (e.g., development of laboratory toxicities, study closure due to DSMB review). ____________________________________________________________________________________________ 10 7 ASSESSMENT OF OUTCOME MEASURES Refer to ICH E6 GCP, Sections 6.7-6.8 (http://www.fda.gov/cder/guidance/959fnl.pdf). 7.1 Specification of the Appropriate Outcome Measures 7.1.1 Primary Outcome Measures 7.1.2 Secondary Outcome Measures ____________________________________________________________________________________________ 11 SAFETY ASSESSMENT AND REPORTING 8 Describe how any adverse events resulting from study procedures will be captured and reported. Describe time frame for reporting and collecting AEs and SAEs. 8.1 Definition of Adverse Event (AE) See ICH E6 GCP, Section 1.2 (http://www.fda.gov/cder/guidance/959fnl.pdf) An AE is any untoward medical occurrence in a subject undergoing a study related procedure and believed reasonably to be caused that study related procedure. Include time period of collection. 8.2 Definition of Serious Adverse Event (SAE) See ICH E6 GCP, Section 1.50 (http://www.fda.gov/cder/guidance/959fnl.pdf). An SAE is any untoward medical occurrence that: Results in death. Is life-threatening. Any adverse experience that places the subject, in the view of the investigator, at immediate risk of death from the reaction as it occurred (i.e., it does not include a reaction that, had it occurred in a more serious form, might have caused death). Requires in-patient hospitalization or prolongation of existing hospitalization. Results in persistent or significant disability or incapacity. Is a congenital anomaly/birth defect. An event that required intervention to prevent permanent impairment or damage. Important medical events that do not result in death, are not life-threatening, or do not require hospitalization may be considered serious adverse events when, based upon appropriate medical judgment, they might jeopardize the subject and might require medical or surgical intervention to prevent one of the outcomes listed above. In addition, protocols may specify other events that require reporting as SAEs (e.g., HIV infection, pregnancy). Include time period of collection. ____________________________________________________________________________________________ 12 8.3 Reporting Procedures Note: All studies which are greater than minimal risk must have an AE reporting system in place. Include details of the protocol-specific reporting procedures, including the individual responsible for each step (e.g., the Investigator, the Medical Monitor), how decisions will be made regarding determining relatedness and grading severity, which forms should be completed, how reports will be distributed and what follow-up is required. Include specific details of reporting procedures for: Deaths and life-threatening events Other SAEs Other adverse events Subsequent review of serious, unexpected and related adverse events by the Medical Monitor, Safety Monitoring Committee, ethics review committee or IRB, the sponsor(s), or the FDA or relevant local regulatory authorities may also result in suspension of the trial. 8.3.1 Serious Adverse Event Detection and Reporting Example text: “For those events meeting the previously described definition of Serious Adverse Events, the completion of a Serious Adverse Event report form is required. Specific information on where to send this form is included in the Manual of Procedures for this study. All serious adverse events will be recorded on the appropriate serious adverse event case report form, followed through resolution by a study physician, and reviewed by a study physician. All deaths, whether associated or not associated, will be recorded on the Serious Event Form and sent by fax within 24 hours of site awareness of the death. Serious adverse events other than death, regardless of relationship, will be reported via fax by the site within 72 hours of becoming aware of the event. Other supporting documentation of the event may be requested by the pharmacovigilance contractor and should be provided as soon as possible. All SAEs will be followed until satisfactory resolution or until the Principal Investigator or Subinvestigator deems the event to be chronic or the patient to be stable. ICH GCP 6, Section 4.11 require that an investigator notifies the sponsor, regulatory authority(ies) and the local IRB immediately of any serious adverse event, deaths, or life____________________________________________________________________________________________ 13 threatening problems that occur in the study. Adverse events and/or laboratory abnormalities identified in the protocol as critical to safety evaluations should be reported in accordance with reporting requirements specified in the protocol. “ 8.3.2 Reporting of Pregnancy State the study’s pregnancy-related policy and procedure. Include appropriate mechanisms for reporting to sponsor, study leadership, IRB, and regulatory agencies. Provide appropriate modifications to study procedures. 8.3.3 Procedures to be Followed in the Event of Abnormal Laboratory Test Values or Abnormal Clinical Findings Collection of laboratory data should be limited to those laboratory parameters that are relevant to safety, study outcome measures and/or clinical outcome. The Toxicity Tables will define what values or findings are considered abnormal. Reporting will be dependent on the abnormality, the study intervention and the study population, but should be stated specifically. Consider the context of the study and adjust reporting procedures appropriately for the study population. Define the circumstances in which abnormal laboratory values will be reported as AEs/SAEs. Generally, in healthy people, a Grade 3 abnormality is an SAE. In sick populations, define in terms of a change from baseline and disease progression. 8.3.4 Type and Duration of the Follow-up of Subjects After Adverse Events See ICH GCP 6, Section 6.8 (http://www.fda.gov/cder/guidance/959fnl.pdf). Describe how adverse events will be followed until resolved or considered stable. Specify procedures for reporting and follow-up of AEs that are consistent with the Schedule of Procedures/Evaluations. 8.4 Halting Rules Describe safety findings that would temporarily suspend enrollment and/or intervention until a safety review is convened (either routine or ad hoc), the objective of which is a decision as to whether the study should continue per protocol, proceed with caution, be further investigated, be discontinued, or be modified and then proceed. ____________________________________________________________________________________________ 14 Examples of findings that might trigger a safety review are the number of SAEs overall, the number of occurrences of a particular type of SAE, severe AEs/reactions, or increased frequency of events. Subsequent review of serious, unexpected and related AEs by the Medical Monitor, DSMB, ethics review committee or IRB, the sponsor(s), or the FDA or relevant local regulatory authorities may suspend further study procedures at a site. ____________________________________________________________________________________________ 15 9 CLINICAL MONITORING STRUCTURE This section will describe the study monitoring to be conducted to ensure the safety and conduct of the study complies with 45 CFR 46, GCP and ICH Guidelines, and other sponsor collaborator’s guidelines, as appropriate. See ICH E6 GCP, Section 5.18 (http://www.fda.gov/cder/guidance/959fnl.pdf). Also refer to: http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.htm#46. 9.1 Site Monitoring Plan Site monitoring is conducted to ensure the human subject protection, study procedures, laboratory, and data collection processes are of high quality and meets sponsor, GCP/ICH and, when appropriate, regulatory guidelines. This section will give a general description of how site monitoring will be conducted. The monitoring plan must include the number of subject charts to be reviewed, which/what proportion of data fields and what will be monitored, and who will be responsible for conducting the monitoring visits, and who will be responsible for ensuring that monitoring findings are addressed. This section is required if a UVa faculty member, employee is the overall PI of this study. ____________________________________________________________________________________________ 16 10 STATISTICAL CONSIDERATIONS 10.1 Study Outcome Measures Discuss how the outcome measures will be measured and transformed, if relevant, before analysis (e.g., is the primary variable binary, categorical, or continuous?) 10.2 Sample Size Considerations Provide information needed to validate your calculations, and also to judge the feasibility of enrolling subjects and obtaining the necessary number of specimens. In particular, specify all of the following: Approach to handling withdrawals and protocol violations Statistical method used to calculate the sample size, with a reference for it and for any software utilized Discuss any measures to decrease bias or increase precision in ascertainment of study endpoints (e.g., blinding of laboratory staff, use of a central laboratory to perform assays). Present calculations from a suitable range of assumptions to gauge the robustness of the proposed sample size. Discuss whether the sample size also provides sufficient power for addressing secondary objectives, or for secondary analyses in key subgroup populations. In some circumstances, exploratory or pilot studies may be planned for convenience of obtaining samples. 10.3 Participant Enrollment and Follow-Up Summarize the total number of enrollees and the total duration of accrual and retention capabilities. 10.4 Analysis Plan This section can be used to elaborate on primary analyses that underlie the sample size calculation in Section 11.2 above and to describe secondary analyses for the primary or ____________________________________________________________________________________________ 17 secondary objectives. Details must be provided in a separate statistical analysis plan written later, but prior to interim or ad hoc analyses. Plans must clearly identify the analyses cohorts, if applicable, and methods to account for missing, unused or spurious data. If specialized statistical techniques (e.g., methods for sequencing or microarray analysis) will be used, please discuss and indicate who will be performing the analysis. ____________________________________________________________________________________________ 18 11 ACCESS TO SOURCE DATA/DOCUMENTS Each participating site will maintain appropriate medical and research records for this trial, in compliance with Section 4.9 of ICH E6 GCP, and regulatory and institutional requirements for the protection of confidentiality of subjects. As part of participating each site will permit authorized representatives of the sponsor(s), and regulatory agencies to examine (and when required by applicable law, to copy) clinical records for the purposes of quality assurance reviews, audits and evaluation of the study safety and progress. Source data are all information, original records of clinical findings, observations, or other activities in a study necessary for the reconstruction and evaluation of the trial. Examples of these original documents and data records include, but are not limited to, hospital records, clinical and office charts, laboratory notes, memoranda, subjects’ diaries or evaluation checklists, pharmacy dispensing records, recorded data from automated instruments, copies or transcriptions certified after verification as being accurate and complete, microfiches, photographic negatives, microfilm or magnetic media, x-rays, and subject files and records kept at the pharmacy, at the laboratories, and medico-technical departments involved in the clinical study. Refer to: http://www.fda.gov/cder/guidance/959fnl.pdf. ____________________________________________________________________________________________ 19 12 QUALITY CONTROL AND QUALITY ASSURANCE This section will briefly indicate the plans for local quality control (QC). Data will be evaluated for compliance with protocol and accuracy in relation to source documents. The study will be conducted in accordance with procedures identified in the protocol. The types of materials to be reviewed, who is responsible, and the schedule for reviews may be specified or referenced in other documents. Types and mechanisms of training of staff for the study should be specified. SOPs must be used at all clinical and laboratory sites. Regular monitoring and an independent audit must be performed according to GCP/ICH (e.g., data monitoring). Briefly describe methods (e.g., internal auditing) for assuring protocol compliance, ethical standards, regulatory compliance, data quality and proper storage and handling of samples. (Refer to ICH GCP E6, Section 5.1 http://www.fda.gov/cder/guidance/959fnl.pdf). ____________________________________________________________________________________________ 20 13 ETHICS/PROTECTION OF HUMAN SUBJECTS This section should include a description of the ethical considerations and context for the conduct of the study. 13.1 Declaration of Helsinki Include this section if applicable. If the study is conducted at international sites, include a statement about compliance with the Declaration of Helsinki. Example text: ”The investigator will ensure that this study is conducted in full conformity with the current revision of the Declaration of Helsinki, or with the International Conference for Harmonisation Good Clinical Practice (ICH-GCP) regulations and guidelines, whichever affords the greater protection to the subject.” 13.2 Institutional Review Board Each participating institution must provide for the review and approval of this protocol and the associated informed consent documents and recruitment material by an appropriate independent ethics review committee (IEC) or Institutional Review Board (IRB) registered with OHRP. Any amendments to the protocol or consent materials must also be approved before they are placed into use. In both the United States and in other countries, only institutions holding a current U. S. Federal-Wide Assurance issued by OHRP may participate. Refer to: http://ohrp.osophs.dhhs.gov. 13.3 Informed Consent Process Refer to ICH GCP E6, Section 4.8 (http://www.fda.gov/cder/guidance/959fnl.pdf). Refer to FDA Regulations on Informed Consent 21 CFR Part 50 - Subpart B (http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?FR=50). Refer to DHHS Regulation on Informed Consent 45 CFR Part 46 - Subpart A, 46.116 (http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.htm#46.116). ____________________________________________________________________________________________ 21 See also Tips on Informed Consents (http://www.hhs.gov/ohrp/humansubjects/guidance/ictips.htm). See also Informed Consent Checklist (http://www.hhs.gov/ohrp/humansubjects/assurance/consentckls.htm) Describe the procedures for obtaining and documenting informed consent of study subjects. Make provisions for special populations, e.g., non-English speakers (refer to: http://www.hhs.gov/ohrp/humansubjects/guidance/ic-non-e.htm), illiterate or non-writing individuals, vulnerable populations. Informed consent is required for all subjects, unless the requirement of informed consent is specifically waived by the IRB. In obtaining and documenting informed consent, the investigator should comply with applicable regulatory requirements and should adhere to GCP and to the ethical principles that have their origin in the Declaration of Helsinki. Prior to the beginning of the trial, the investigator should have the IRB written approval/favorable opinion of the written informed consent form(s) and any other written information to be provided to the subjects. Identify different consent forms that are needed for the study (e.g., screening, study participation, HIV screening, future use specimens, plasmapheresis, assent form for minors). Example text: “Informed consent is a process that is initiated prior to the individual’s agreeing to participate in the study and continuing throughout the individual’s study participation. Extensive discussion of risks and possible benefits of participation in this study will be provided to the subjects and their families. Consent forms describing in detail the study procedures and risks are given to the subject and written documentation of informed consent is required prior to enrolling in the study. Consent forms will be IRB approved and the subject will be asked to read and review the document. Upon reviewing the document, the investigator will explain the research study to the subject and answer any questions that may arise. The subjects will sign the informed consent document prior to being enrolled in the study. The subjects should have the opportunity to discuss the study with their surrogates or think about it prior to agreeing to participate. The subjects may withdraw consent at any time throughout the course of the study. A copy of the informed consent document will be given to the subjects for their records. The rights and welfare of the subjects will be protected by emphasizing to them that the quality of their medical care will not be adversely affected if they decline to participate in this study.” Provide each institution with a sample consent form for subject participation. The consent form should be separate from the protocol document. ____________________________________________________________________________________________ 22 13.3.1 Informed Consent/Assent Process (in Case of a Minor or others unable to consent for themselves) Refer to ICH E6, Section 4.8.12 (http://www.fda.gov/cder/guidance/959fnl.pdf). When a study includes subjects who may be enrolled in the study only with the consent of the subject’s legally authorized representative (e.g., minors or subjects unable to consent for themselves), the subject should be informed about the study to the extent compatible with the subject’s understanding. If capable, the subject should assent and sign and personally date the written consent form. A separate IRB-approved assent form, describing (in simplified terms) the details of the study, study procedures and risks may be used. Assent forms do not substitute for the consent form signed by the subject’s legally acceptable representative. Consult with the institutions policies regarding enrolling participants who are unable to provide informed consent for themselves. Subjects who are unable to give consent for themselves should not be enrolled in nontherapeutic research unless the objectives of the research cannot be met by enrolling only persons who are able to give consent for their participation. The reviewing IRB must give approval or a favorable opinion on their inclusion. 13.4 Exclusion of Women, Minorities, and Children (Special Populations) If the study intends to exclude any special populations, justify the exclusion of women, minorities or children in the context of the study design. 13.5 Subject Confidentiality Include procedures for maintaining subject confidentiality, any special data security requirements, and record retention per the sponsor’s requirements. Subject confidentiality is strictly held in trust by the participating investigators, their staff, and the sponsor(s) and their agents. This confidentiality is extended to cover testing of biological samples and genetic tests in addition to the clinical information relating to participating subjects. The study protocol, documentation, data and all other information generated will be held in strict confidence. No information concerning the study or the data will be released to any unauthorized third party without prior written approval of the sponsor. The study monitor or other authorized representatives of the sponsor may inspect all documents and records required to be maintained by the Investigator, including but not limited to, medical ____________________________________________________________________________________________ 23 records (office, clinic or hospital) and pharmacy records for the subjects in this study. The clinical study site will permit access to such records. 13.6 Future Use of Stored Specimens If residual specimens will be maintained after the study is complete, include the provisions for consent and the options that are available for the volunteer to agree to the future use of his/her specimens. Specify the location(s), if other than the clinical site, where specimens will be maintained, if the site's IRB will review future studies, and protections of confidentiality for any future studies with the stored specimens, e.g., specimens will be coded, bar-coded, de-linked. Include a statement that genetic testing will not be performed if required by the IRB. Refer to Human Research Regulation Chart 2 at: http://www.hhs.gov/ohrp/humansubjects/guidance/decisioncharts.htm. ____________________________________________________________________________________________ 24 14 DATA HANDLING AND RECORD KEEPING Include instructions for special data handling or record keeping procedures required for maintaining subject confidentiality, any special data security requirements, and record retention per the sponsor’s requirements in this section. Briefly describe steps to be taken to assure that the data collected are accurate, consistent, complete and reliable and in accordance with ICH GCP guidelines and 21 CFR Part 11. The description should include reference to source documentation, case report forms, instructions for completing forms, data handling procedures, and procedures for data monitoring. Details may be provided in a Manual of Procedures, User’s Guide or other citable reference document. Refer to: http://www.fda.gov/ora/compliance_ref/part11/ 14.1 Data Management Responsibilities Describe responsibilities for data handling and record keeping as they specifically relate to the sponsor, clinical site, laboratory, and data coordinating center. Information should include the role in data collection, review of data, study materials, and reports, as well as retention of source documents, files, and records. Describe coding dictionaries to be used and reconciliation processes (if applicable). All source documents and laboratory reports must be reviewed by the clinical team and data entry staff, who will ensure that they are accurate and complete. Adverse Events must be graded, assessed for severity and causality and reviewed by the site Principal Investigator or designee. Data collection is the responsibility of the study staff at the site under the supervision of the site Principal Investigator. During the study, the Investigator must maintain complete and accurate documentation for the study. If data are to be generated in one location and transferred to another group, describe the responsibilities of each party. Indicate the roles of each party with regard to interpretation of data, plans for analysis, review of tables and listings, and plans for reporting. ____________________________________________________________________________________________ 25 14.2 Data Capture Methods Provide details regarding the type of data capture that will be used for the study. Specify whether it will be paper or electronic, distributed or central, batched or ongoing processing, and any related requirements. Indicate expectations for time for submission of CRFs. 14.3 Types of Data Indicate the types of data that will be collected. 14.4 Timing/Reports Indicate the schedule for data review and reports. Specify whether reviews or reports are ongoing, interim, or periodic. Identify plans for data analysis and submission of reports, steps for freezing the data prior to analysis, and precautions related to blinded data. Indicate whether and when coding is to occur. 14.5 Study Records Retention Specify the length of time for the investigator to maintain all records pertaining to this study. Indicate whether permission is required prior to destruction of records. 14.6 Protocol Deviations Plans for detecting, reviewing and reporting deviations from the protocol should be described. A statement may be included to indicate that exemptions for specific inclusion/exclusion deviations are not allowed (if not handled separately in an investigator agreement) and/or provisions for approval of inclusion/exclusion deviations can be described. ____________________________________________________________________________________________ 26 15 PUBLICATION POLICY If appropriate, the publication policy may be described in the study Manual of Procedures (MOP). The publication and authorship policies should be determined and clearly outlined in this section. Refer to contract or clinical trials agreements. Policies regarding substudies should be outlined in this section. The following language may used in the protocol: Following completion of the study, the investigator may publish the results of this research in a scientific journal. The International Committee of Medical Journal Editors (ICMJE) member journals have adopted a trials-registration policy as a condition for publication. This policy requires that all clinical trials be registered in a public trials registry such as ClinicalTrials.gov, which is sponsored by the National Library of Medicine. Other biomedical journals are considering adopting similar policies. It is the responsibility of the sponsor to register this trial in an acceptable registry. Any clinical trial starting enrollment after 01 July 2005 must be registered either on or before the onset of patient enrollment. For trials that began enrollment prior to this date, the ICMJE member journals will require registration by 13 September 2005 before considering the results of the trial for publication. The ICMJE defines a clinical trial as any research project that prospectively assigns human subjects to intervention or comparison groups to study the cause-and-effect relationship between a medical intervention and a health outcome. Studies designed for other purposes, such as to study pharmacokinetics or major toxicity (eg, Phase 1 trials), would be exempt from this policy. ____________________________________________________________________________________________ 27 16 LITERATURE REFERENCES Include a list of relevant literature references in this section. Use a consistent, standard, modern format, which might be dependent upon the required format for the anticipated journal for publication (e.g., NEJM, JAMA). The preferred format is the Vancouver format, used in the American Medical Association Manual of Style. Examples: Journal citation: Davis JT, Allen HD, Powers JD, Cohen DM. Population requirements for capitation planning in pediatric cardiac surgery. Arch Pediatr Adolesc Med. 1996;150(1):257-259. Whole Book citation: Sherlock S, Dooley J. Diseases of the Liver and Biliary System. 9th ed. Oxford, England: Blackwell Scientific Publications; 1993. Chapter in a Book citation: Cole BR. Cystinosis and cystinuria. In: Jacobson HR, Striker GE, Klarh S, eds. The Principles and Practice of Nephrology. Philadelphia, PA: BC Decker Inc.; 1991:396-403. A full listing of Vancouver style guidelines can be found at: International Committee of Medical Journal Editors. Uniform Requirements for Manuscripts Submitted to Biomedical Journals. JAMA. 1997;277:927-934. You may also refer to: http://www.library.uwa.edu.au/guides/citingsources/vancouver.html ____________________________________________________________________________________________ 28 SUPPLEMENTS/APPENDICES Required Documents: Provide with protocol: Consent Form Assent Form, if applicable Future Use Consent, if applicable Schedule of Events Can be provided with the protocol or in separate documents Manual of Procedures Safety Monitoring Plan Site Monitoring Plan Copies of Case Report Form(s) Additional/optional supplements: Biosafety Precautions Repository Instructions Laboratory Handling Site Roster ____________________________________________________________________________________________ 29 Appendix A: Study Schedule Time Point 4, etc. Study Completion Premature Discontinuation Time Point 3 Time Point 2 Time Point 1 Baseline Screening Follow-Up Schedule X X X X X Procedures Signed Consent Form X X Assessment of Eligibility Criteria X X Review of Medical History X X Review of Concomitant Medications X X Physical Exam Study Procedures Complete Clinical Laboratory Research Laboratory X X X X SymptomDirected X (X) (X) (X) (X) Vital Signs (X) (X) (X) (X) (X) (X) (X) (X) (X) X X Assessment of Adverse Events Other Procedures X Chemistry X X (X) (X) (X) (X) X X Hematology X X (X) (X) (X) (X) X X Urinalysis X X (X) (X) (X) (X) X X Immunology __mL whole blood X (X) (X) X X (X) (X) (X) (X) (X) (X) – As indicated/appropriate. Provide a list of tests to be done, e.g.: Hematology – Hemoglobin, hematocrit, WBC and differential count, platelet count Biochemistry – Sodium, potassium, chloride, urea, creatinine, glucose, uric acid, bicarbonate, amylase, lipase, albumin, total bilirubin, cholesterol, triglycerides, and CPK, as appropriate for the study. These are examples, specify list of tests. Urinalysis – Protein and glucose, as appropriate for the study Immunology – Specify specimen types for non-standard laboratory assays Other – Other procedures that are done to evaluate outcome measures (e.g., photographs, X-rays) Intervention – Modify as appropriate if intervention is administered more than once throughout the study Specify time points for follow-up in days, weeks, or months, as appropriate for protocol. At baseline, all procedures should be done before intervention. Indicate volume of blood if frequent or large phlebotomies are part of the protocol over two months. ____________________________________________________________________________________________ 30 ____________________________________________________________________________________________ 31 EXAMPLE: DATA AND SAFETY MONITORING PLAN 1. Definition: 1.1 How will you define adverse events (AE)) for this study? An adverse event will be considered any undesirable sign, symptom or medical or psychological condition even if the event is not considered to be related to the investigational drug/device/intervention. Medical condition/diseases present before starting the investigational drug/intervention will be considered adverse events only if they worsen after starting study treatment/intervention. An adverse event is also any undesirable and unintended effect of research occurring in human subjects as a result of the collection of identifiable private information under the research. Adverse events also include any problems associated with the use of an investigational device that adversely affects the rights, safety or welfare of subjects. 1.2 How will you define serious adverse events? A serious adverse event will be considered any undesirable sign, symptom, or medical condition which is fatal, is life-threatening, requires or prolongs inpatient hospitalization, results in persistent or significant disability/incapacity, constitutes a congenital anomaly or birth defect, is medically significant and which the investigator regards as serious based on appropriate medical judgment. An important medical event is any AE that may not result in death, be lifethreatening, or require hospitalization but may be considered an SAE when, based upon appropriate medical judgment, it may jeopardize the patient and may require medical or surgical intervention to prevent one of the outcomes listed in the definitions of SAEs. 1.3 What is the definition of an unanticipated problem? An unanticipated problem is any event, experience that meets ALL 3 criteria below: Is unexpected in terms of nature, severity or frequency given the research procedures that are described in the protocol-related documents AND in the characteristics of the subject population being studies Related or possibly related to participation in research. This means that there is a reasonable possibility that the incident may have been caused by the procedures involved in the research study. The incident suggests that the research placed the subject or others at greater risk of harm than was previously known or recognized OR results in actual harm to the subject or others 1.4 What is the definition of a protocol violation? A protocol violation is defined as any change, deviation, or departure from the study design or procedures of a research project that is NOT approved by the IRB-HSR prior to its initiation or implementation, OR deviation from standard operating procedures, Good Clinical Practices (GCPs), federal, state or local regulations. ____________________________________________________________________________________________ 32 Protocol violations may or may not be under the control of the study team or UVa staff. These protocol violations may be major or minor violations. 1.5 If pregnancy occurs how will this information be managed? _____ Adverse Event- will follow adverse event recording and reporting procedures outlined in section 3. _____ Unanticipated Problems- will follow Unanticipated Problem recording and reporting procedures outlined in section 3. _____ Other 2. Identified risks and plans to minimize risk 2.1 What risks are expected due to the intervention in this protocol? Expected: is identified in nature, severity or frequency in the study documentation (protocol, consent, Investigator Brochure, package insert etc) is considered an expected. The risks should be consistent with those in the consent form and the investigator’s brochure (if applicable), although they should be written in technical terms in the protocol and in lay terminology in the consent form. Separate risks by source of risk: (example: Risk of Radiation, Risk of Study Drug, Risk of investigational device, etc.) If there is more than one source of risk- insert a separate table for each risk. If the study involves a removable device- include the potential risk from device removal List the most serious risk first. Expected Risks related to study participation. List the risks below Add additional rows if needed Delete this row if this protocol does not represent reproductive risks. Frequency Check one frequency from each box below ____Occurs frequently ____Occurs infrequently ____Occurs rarely ____Frequency unknown Minimized due to the requirements of this protocol. Reproductive Risks Specify potential reproductive risks Violation of subject’s privacy and confidentiality Minimized due to the requirements of the privacy plan in this protocol ____________________________________________________________________________________________ 33 Delete this row if this protocol does not include Genetic Research Risk of Genetic Research See Genetic Research Section for Risks NA 2.2 List by bullet format a summary of safety tests/procedures/observations to be performed. Particularly list those tests or procedures that screen out ineligible research subjects and those that monitor toxicity and other adverse outcomes. For example: Adequate screening, pregnancy testing, AE monitoring at each visit, etc.) 2.3 Under what criteria would an INDIVIDUAL SUBJECT’S study treatment or study participation be stopped or modified _____At subject, PI or sponsor’s request _____Treatment would be stopped if the subject had a serious adverse event deemed related to study, or study drug will be increased if the subject tolerates dosing insert details:_ 2.4 Under what criteria would THE ENTIRE STUDY need to be stopped. These are called stopping rules for early termination of the entire study. List criteria regardless of whether the study is sponsored or not. Be sure to include any criteria for which the UVa PI would halt the study at UVa. Check all that apply _____Per IRB, PI, DSMB, or sponsor discretion _____Other: specify 2.5 What are the criteria for breaking the blind/mask? _____NA – Not blinded/masked _____Other: specify 2.6 How will subject withdrawals/dropouts be reported to the IRB prior to study completion? _____Continuation status report _____Other: describe ____________________________________________________________________________________________ 34 3. Adverse Event / Unanticipated Problem Recording and Reporting 3.1 Will all adverse events, as defined in section 1.1, be collected/recorded? ►IF NO, what criteria will be used? _____Only adverse events deemed related/possibly related to study _____Only adverse events that are deemed serious _____Only adverse events that are deemed related AND serious _____Other: specify: 3.2 How will adverse event data be collected/recorded? Check all that apply _____Paper AE forms/source documents _____Spreadsheet (paper or electronic) _____Database specify name/type of database(s): 3.3. How will AEs be classified/graded? Check all that apply _____World Health Organization Criteria (WHO) _____NCI Common Toxicity Criteria, Version 2.0/ NCI Common Terminology Criteria, Version 3.0 _____NCI CTCAE Version 4.0 _____Mild/Moderate/Severe ____Serious/Not serious _____Other: specify 3.4 What scale will the PI use when evaluating the relatedness of adverse events to the study participation? Check all that apply. _____The PI will determine the relationship of adverse events to the study using the following scale: Related: Possibly related: Unrelated: AE is clearly related to the intervention AE may be related to the intervention AE is clearly not related to intervention _____The PI will use an alternative attribution scale. specify 3.5 When will recording/reporting of adverse events/unanticipated problems begin? _____After subject signs consent ____________________________________________________________________________________________ 35 _____After subject begins study drug/ device placement/intervention /study-related procedure/specimen collection _____Other: specify 3.6 When will the recording/reporting of adverse events/unanticipated problems end? _____End of study drug/device/intervention/participation _____30 days post study drug/device/intervention _____Subject completes intervention and follow up period of protocol _____Other: specify 3.7 How will Adverse Events, Unanticipated Problems, Protocol Violations be reported? Complete the table below to answer this question Type of Event To whom will it be reported: Any internal event resulting IRB in death that is deemed DEFINITELY related to (caused by) study participation Internal, Serious, IRB Unexpected adverse event TIP: if you answered NO to question3.1- modify this section to include only those AE’s you plan to record. ( example: if you are recording only those that are related/ possibly related- state “ Internal, Serious, Related or Possibly Related, Unexpected adverse events. Delete this row if the IRB study does not involve a device. For Device Studies: Unanticipated adverse device effects (internal) Unanticipated Problems IRB that are not adverse Time Frame for Reporting Within 24 hours How reported? Within 7 calendar days from the time the study team received knowledge of the event. AE Reporting Form See Appendix Phone call and case report form Timeline includes submission of signed hardcopy of AE form. Within 10 day calendar days of the study team receiving knowledge of the event Within 7 calendar days from the time ADE Reporting Form See Appendix Unanticipated Problem report form. ____________________________________________________________________________________________ 36 events or protocol violations Protocol Violations IRB the study team received knowledge of the event. Within 7 calendar days from the time the study team received knowledge of the event. See Appendix Protocol Violation and Enrollment Exception Reporting Form See Appendix OUTSIDE SPONSOR All Serious adverse events Sponsor TIP: if you answered NO to question3.1- modify this section to include only those AE’s you plan to record. ( example: if you are recording only those that are related/ possibly related- state “ Serious, Related or Possibly Related adverse events. Internal Serious and Sponsor Unexpected adverse event resulting in change to the protocol or consent.. Delete this row if the Sponsor study does not involve a device. For Device Studies: Unanticipated adverse device effects (internal) Unanticipated Problem Sponsor Insert time frame to report to sponsor Insert name of form and method of reporting to the sponsor Within 7 calendar days from the time the study team received knowledge of the event. Timeline includes submission of signed hardcopy of AE form Within 10 day of the study team receiving knowledge of the event Insert name of form and method of reporting to the sponsor Insert required timeframe. If there is no Insert reporting method Insert reporting method ____________________________________________________________________________________________ 37 Protocol violations Sponsor information from the sponsor use the same time frames as abovein reporting External, serious and unexpected AE resulting in Change to the protocol or consent to the IRB. Insert required timeframe Insert reporting method Delete the section below if the study does not involve an independent DSMB/DSMC IF YOU REFERENCE THE SPONSORS PROTOCOL IN THE TABLE BELOW MAKE SURE THE SECTION IN THE SPONSORS PROTOCOL ADEQUATELY ANSWERS THE QUESTIONS INDEPENDENT DSMB/DSMC Insert what items the DSMB/DSMC wants to Review (AEs, SAEs, early withdrawals, etc) Unanticipated Problem DSMB/DSMC Insert reporting method Insert reporting method DSMB/DSMC Insert reporting method DSMB/DSMC Reports IRB Insert required timeframe 15 calendar days of the study team receiving the report Copy of DSMB/ DSMC report Delete the section below if the study does not involve an IND/IDE in which a UVa faculty member is the PI of the IND/IDE. UVa PI HELD IND/IDE Life-threatening and/or FDA fatal unexpected events related or possibly related to the use of the investigational agent. Serious, unexpected and FDA related or possibly related adverse events Delete this row if the FDA study does not involve a device For Device Studies: Within 7 calendar days of the study team learning of the event Form FDA 3500A (MedWatch) or narrative Within 15 calendar days after the study team receives knowledge of the event Within 10 working days of the study team receiving knowledge of the event Form FDA 3500A (MedWatch) or narrative Form FDA 3500A (MedWatch) or narrative ____________________________________________________________________________________________ 38 Unanticipated adverse device effects (internal or external) All adverse events FDA Annually IND annual report Delete the section below if a UVA PI is not the overall PI of the multi-site trial and or the multi site study does not involve an IND/IDE held by the UVa faculty member. IF YOU REFERENCE THE SPONSORS PROTOCOL MAKE SURE THE SECTION IN THE SPONSORS PROTOCOL ADEQUATELY ANSWERS THE QUESTIONS IN THE TABLE BELOW The IRB-HSR strongly encourages PIs that are also holding their own IND/IDE to utilize the IRB-HSR IRB online adverse events database for RECORDING all adverse events. The principal investigator can then use this database to produce a report of all adverse events on the study to do an aggregate review, which is helpful since an annual report to the FDA containing this information is required by the FDA. If the Cancer Center Protocol and Review Committee (PRC) will review this protocol additional reporting requirements are found in the PRC section of this protocol. UVA PI of MULTI-SITE TRIAL Serious, unexpected and All Research related or possibly Sites related adverse events Within 15 days after the Overall PI receives knowledge of the event. IND/IDE Safety Report (Cover letter, copy of MedWatch/narrative) Delete this row if the All Research study does not involve Sites a device. For Device Studies: Unanticipated adverse device effects (internal or external) Unanticipated Problem All Research Sites Within 15 calendar days from the time the Overall PI receives knowledge of the event. Letter to Participating PIs, Copy of MedWatch or narrative Within 15 calendar days from the time the Overall PI receives knowledge of the event. Letter to Participating PIs, Copy of MedWatch or narrative 4. How will the endpoint data be collected/recorded. Check all that apply _____Protocol specific case report forms _____Source documents _____Database: specify _____Other: specify 5. Data and Safety Oversight Responsibility 5.1. Who is responsible for overseeing safety data for this study ? e.g. Who is looking at data in aggregate form to identify trends? ____________________________________________________________________________________________ 39 Check all that apply _____No additional oversight body other than the overall PI at UVa (skip question 5.2) _____Medical Monitor This could include such things as the overall PI of a multisite trial _____DSMB/ DSMC- If your study is NIH funded, check with the center to determine if they require a DSMB for this study. _____Research Monitor: Insert Name ____________________________ Required for protocols funded by the Department of Defense _____Other: specify ________________ 5.2. What is the composition of the reviewing body and how is it affiliated with the sponsor? Members of the study team may NOT also be members of the DMSB. 5.3. What items will be included in the aggregate review conducted by the PI? Check all that apply. _____NA- PI is not the overall person overseeing the safety data for this study. _____All adverse events _____Unanticipated Problems _____Protocol violations _____Audit results _____Application of dose finding escalation/de-escalation rules These should be outlined under 2.4. _____Application of study designed stopping/decision rules _____Early withdrawals _____Whether the study accrual pattern warrants continuation/action _____Endpoint data _____Other: (specify) ______ 5.4 How often will aggregate review occur? For additional information on aggregate review see: www.virginia.edu/vpr/irb/hsr/continuations.html#aggreview _____NA- PI is not the overall person overseeing the safety data for this study. _____Annually ____________________________________________________________________________________________ 40 _____Monthly _____Other: specify 5.5. How often will a report, regarding the outcome of the review by the DSMB/DSMC, be sent to the sites? _____ NA- there is no DSMB/ DSMC overseeing this study _____Every six months _____Once a year _____Other: specify 5.6. How will a report of the information discussed in question 5.4 OR 5.5 be submitted to the IRB? _____Part of continuation status report _____Separate report from DSMB/DSMC _____Other: specify ____________________________________________________________________________________________ 41